Dear Medicare: Don't Put Vulnerable Patients at Risk

Here is why the Part B Pilot is just wrong

It is safe to say there is broad agreement -- among policymakers, healthcare providers, and patients alike -- that steps must be taken to make prescription drugs and treatments more affordable. Opinion varies, however, on exactly what direction to take to accomplish this goal. The Centers for Medicare & Medicaid Services (CMS) has recommended a path that we fear many physicians and their patients simply can't navigate because it is paved by false assumptions that endanger vulnerable Medicare patients.

In an effort to lower drug spending, CMS has devised a plan to incentivize physicians to prescribe less expensive drugs under the Medicare Part B program. But the unfortunate reality -- one that CMS has yet to acknowledge -- is that there are no "cheap" yet clinically equivalent alternatives for some of the most advanced and expensive drugs available today. Biologic therapies and chemotherapies are a lifeline for Medicare patients battling rheumatic disease and many cancers, but equivalent therapy options available under Part B are already few, and sometimes costly.

It is therefore much to the dismay of the rheumatology and oncology communities that CMS is moving forward with its new Part B payment test based on this very troubling premise -- that physicians always have less expensive yet equally effective therapy options from which to choose, and that cutting reimbursement rates for Medicare drugs across the board will incentivize physicians to use less costly alternatives. It's a faulty premise that threatens access to care for the nation's millions of Medicare patients fighting cancer and rheumatic disease.

Our organizations, the American College of Rheumatology (ACR) and The US Oncology Network (USON), agree with CMS on two things: We need to make the cost of life-saving and life-sustaining drugs more affordable, and all Medicare patients have the right to receive clinically appropriate, high-quality care. However, we strongly disagree with CMS on its proposed method for advancing these goals. Moreover, we are deeply concerned about the serious, negative consequences the proposal will have on the millions of rheumatic disease and cancer patients who do not neatly fit into CMS' cost-containment hypothesis.

Sometimes our patients' best and only hope for disease treatment and remission is a therapy that is both effective and expensive. For rheumatology patients, the advent of advanced biologic therapies has been life changing, helping to double remission rates for diseases like rheumatoid arthritis (RA) since 1990, and allowing many patients to avoid long-term disability, chronic pain, additional health complications, and early death. For cancer patients, treatment plans alter repeatedly, underscoring the need for access to any and all therapies oncologists prescribe to offer the best chance for survival.

We are fortunate to live in an age where biologic therapies and chemotherapies exist. Unfortunately, despite progress, the options available to Medicare patients are already too few. Furthermore, each patient is unique, and complex therapies cannot easily be substituted. With rheumatic disease, it is often the case that once a patient is fortunate enough to find a drug that works, it is the only option. Similarly, treatment protocols and standards mean that cancer patients often have only one suitable treatment option. The CMS proposal -- which would limit the availability of life-saving and life-sustaining treatments based on cost -- simply does not consider the distinct individual needs of cancer and rheumatic disease patients.

The CMS proposal also threatens to exacerbate existing access issues by driving more of our Medicare patients into less safe or more expensive settings to receive their care. Many rheumatologists and oncologists have already been forced to close their infusion centers and community-based cancer clinics because existing reimbursement rates do not always adequately cover the cost of obtaining and administering these therapies.

An additional payment cut -- like the one proposed in the Part B payment test -- would force even more of our Medicare patients into alternative, less desirable and more expensive settings to receive biologic and chemotherapy infusions. Some alternative settings, such as a patient's home, are not properly supervised and thereby increase the risk of death from infusion reactions. Other settings, including hospitals, will increase out-of-pocket costs and create longer travel times for patients who are already suffering from life-threatening disease.

It's true, sometimes life-saving drugs are expensive, but reducing Medicare Part B drug spending by limiting patient access to these advanced therapies is not a sustainable solution. We urge CMS to withdraw this proposal and instead work with physician stakeholders to create comprehensive reforms that reduce healthcare costs without putting patient access to needed biologic and chemotherapy drugs at risk.

Joan Von Feldt, MD, MSEd, is President of the American College of Rheumatology and Professor of Medicine at the Perelman School of Medicine at the University of Pennsylvania. Michael Seiden, MD, PhD, is a Senior Vice President and Chief Medical Officer for McKesson Specialty Health as well as the Chief Medical Officer of the US Oncology Network.

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